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ESTATE OF KRIESEL v. COMMISSIONER

Docket No. 647-75.

37 T.C.M. 264 (1978)

T.C. Memo. 1978-50

Estate of Ralph R. Kriesel, Transferee of the Assets of Ralph R. Kriesel Company, Carl W. Cummins, Jr., and First Trust Company of St. Paul, Executors v. Commissioner.

United States Tax Court.

Filed February 6, 1978.

Attorney(s) appearing for the Case

William H. Hippee, Jr., and John W. Windhorst, 2300 First Nat'l Bank Bldg., Minneapolis, Minn., for the petitioner. David J. Duez, for the respondent.

Memorandum Opinion

FAY, Judge:

Respondent determined a liability against the Estate of Ralph R. Kriesel, as transferee, with respect to a deficiency determined against the Ralph R. Kriesel Company (the Kriesel Company), transferor, in the amount of $102,431.02 for the corporation's taxable year ended March 31, 1970.

Due to concessions, the sole issue remaining for decision is whether during the taxable year in issue the Kriesel Company was availed...

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